Second Superseding Indictment, United States v. Ronnell Bowman et al., Case No. 23-CR-77 (March 11, 2025)

Summary

A Second Superseding Indictment against Ronnell Bowman, Ronnie Jackson and Lawrence Turner in Case No. 23-CR-77, U.S. District Court for the Eastern District of Wisconsin, filed March 11, 2025 as Document 780. Count One charges Bowman and Jackson with a mail fraud conspiracy from about March 2020 through February 2022, alleging false Pandemic Unemployment Assistance claims to California EDD and other state UI programs using third parties' personal information. The grand jury alleges the funds bought firearms, jewelry, clothing and vacations and were used to solicit murder for hire. Other counts charge murder for hire and conspiracy resulting in a death, a firearm count, a firearms conspiracy, and witness tampering and obstruction counts against Bowman. A forfeiture notice follows.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

UNITED STATES DISTRICT COURT 3
EASTERN DISTRICT OF WISCONSIN

UNITED STATES OF AMERICA,
Plaintiff,
Vv. Case No. 23-CR-77
RONNELL BOWMAN, [18 U.S.C. §§ 2(a), 371, 924(c), 1512,
RONNIE JACKSON, and 1349, & 1958]
LAWRENCE TURNER,
Defendants.

SECOND SUPERSEDING INDICTMENT

THE GRAND JURY CHARGES THAT:

Background Allegations

At times material to this Second Superseding Indictment:

1. The “Wild 100s” was a street gang operating in the Milwaukee,
Wisconsin area. The defendants herein, who are all members and affiliates of the
“Wild 100s,” engaged in various criminal activities, including crimes of violence,
illegal firearms possession, conspiracy, and fraud in Milwaukee and elsewhere.

2. Unemployment Insurance (“UI”) is a joint state and federal program
overseen by the U.S. Department of Labor that provides monetary benefits to eligible
workers who became unemployed through no fault of their own.

3. Beginning in March 2020, in response to the COVID-19 pandemic,

several federal programs expanded UI eligibility and increased UI benefits, including

Case 2:23-cr-00077-JPS Filed 03/11/25 Page1of1i2 Document 780
the Pandemic Unemployment Assistance Program (“PUA”). PUA federal funds were
then distributed to the states’ UI programs.

A, In the State of California, the Employment Development Department
(“EDD”) administered the state’s UI program. Applicants had to submit online
applications and respond to various questions to establish they were eligible to
receive UI benefits, including by providing their name, Social Security Number
. (“SSN”), and mailing address, among other things. Applicants also had to self-certify
that they met a COVID-19-related reason for being unemployed, partially employed,
or unable to work. The EDD relied upon the information in the online application to
determine eligibility for UI benefits. Once an application was approved, the EDD
typically distributed state and federal UI benefits electronically to a debit card in the
claimant’s name, which the claimant could use to withdraw funds and make
purchases. These debit cards were sent via the U.S. Postal Service to the address the

claimant provided. Claimants could activate their debit cards via telephone or online.

COUNT ONE

The Conspiracy and its Object

5. Beginning in or about March 2020, and continuing through in or about
February 2022, in the State and Eastern District of Wisconsin, the State and

Southern District of Texas, and elsewhere,

RONNELL BOWMAN and
RONNIE JACKSON

knowingly conspired with each other and others, known and unknown to the Grand

Jury, to devise and participate in a scheme to defraud the United States Department

2

Case 2:23-cr-00077-JPS Filed 03/11/25 Page2of12 Document 780
of Labor by means of materially false and fraudulent pretenses, representations, and
promises (the “scheme”), which is further described below, and for the purpose of
executing that scheme caused mail matter to be sent by the Postal Service, in
violation of Title 18, United States Code, Section 1341.

6. It was part of the scheme that the defendants and their co-conspirators
acquired the personal identifying information (“PII”) of third parties and used that
PII to submit false and fraudulent PUA claims to California EDD and other state UI
programs.

7. It was further part of the scheme that the defendants provided
addresses that they controlled on the fraudulent PUA applications, which caused
debit cards loaded with the fraudulently obtained monetary benefits to be sent to
those addresses under their control.

8. It was further part of the scheme that the defendants collected and
utilized those fraudulently obtained debit cards for their own benefit, as further
described below.

Manner and Means of the Conspiracy

9. In order to accomplish the purpose of the conspiracy, the defendants
used, and caused others to use, the following manner and means:

a. The defendants electronically submitted fraudulent UI applications to

multiple states on behalf of themselves and others, in which they made
materially false and fraudulent representations.

b. It was further part of the scheme that the defendants communicated

3

Case 2:23-cr-00077-JPS Filed 03/11/25 Page3o0f12 Document 780
with each other and other co-conspirators about submitting the
fraudulent PUA claims and members of the conspiracy taught each
other how to submit false and fraudulent PUA claims to California EDD
and other state UI programs.

c. The defendants’ materially false and fraudulent representations caused
California EDD and other states to award PUA funds in the claimants’
names through pre-loaded debit cards mailed to various locations,
including the Eastern District of Wisconsin.

d. As a result of the scheme, the defendants fraudulently obtained federal
PUA benefits from California EDD and other state-administered UI
programs to which they were not entitled.

e. The defendants used the fraudulently obtained PUA funds to purchase,
among other things, firearms, jewelry, clothing, vacations, and to solicit
murder for hire.

Overt Acts in Furtherance of the Conspiracy

10. To further the conspiracy, the conspirators committed acts in the
Eastern District of Wisconsin, and the Southern District of Texas, including but not
limited to:

a. On or about June 9, 2021, BOWMAN caused to be mailed an envelope

containing a PUA debit card that was delivered to XXXXX Micmac

Court, Cypress, Texas through the United States Postal Service.

All in violation of Title 18, United States Code, Sections 1349 and 2(a).

4

Case 2:23-cr-00077-JPS Filed 03/11/25 Page4of12 Document 780
COUNT TWO

THE GRAND JURY FURTHER CHARGES THAT:
Beginning on or about March 15, 2021, and continuing until on or about April
5, 2021, within the State and Eastern District of Wisconsin, the State and Southern

District of Texas, and elsewhere,

RONNELL BOWMAN,
RONNIE JACKSON, and

LAWRENCE TURNER
did knowingly and intentionally use and cause to be used a facility of interstate
commerce, with intent that a murder be committed in violation of the laws of
Wisconsin and the United States, as consideration for the receipt of, and as
consideration for a promise and agreement to pay, something of pecuniary value;
namely, the defendants used and caused to be used means of transportation and
communication, including a Kia Soul bearing Michigan license plate EBZ-9428,
cellular telephones operating on interstate networks, and social media platforms,
with the intent that a murder be committed as consideration for the receipt of money,

and which resulted in the death of N.B.

In violation of Title 18, United States Code, Sections 1958 and 2(a).

5

Case 2:23-cr-00077-JPS Filed 03/11/25 Page5of12 Document 780
COUNT THREE
THE GRAND JURY FURTHER CHARGES THAT:
Beginning on or about March 15, 2021, and continuing until on or about April
5, 2021, within the State and Eastern District of Wisconsin, the State and Southern

District of Texas, and elsewhere,

RONNELL BOWMAN,
RONNIE JACKSON, and
LAWRENCE TURNER
did knowingly and intentionally conspire to use and cause another to use a facility of
interstate commerce, with intent that a murder be committed in violation of the laws
of Wisconsin and the United States, as consideration for the receipt of, and as
consideration for a promise and agreement to pay, something of pecuniary value,

which resulted in the death of N.B.

In violation of Title 18, United States Code, Sections 1958 and 2(a).

6
Case 2:23-cr-00077-JPS Filed 03/11/25 Page6of12 Document 780
COUNT FOUR

THE GRAND JURY FURTHER CHARGES THAT:
On or about April 5, 2021, in the State and Eastern District of Wisconsin,
RONNELL BOWMAN,
RONNIE JACKSON, and
LAWRENCE TURNER
knowingly used, carried, and discharged a firearm during and in relation to a crime
of violence, that is, Murder for Hire and Conspiracy to Commit Murder for Hire, as

charged in Counts Two and Three of this Second Superseding Indictment.

In violation of Title 18, United States Code, Sections 924(c)(1)(A)Gii) and 2(a).

7

Case 2:23-cr-00077-JPS Filed 03/11/25 Page 7of12 Document 780
COUNT FIVE

THE GRAND JURY FURTHER CHARGES THAT:
1. Beginning in or about July 2020 and continuing until on or about April
21, 2023, in the State and Eastern District of Wisconsin, the State and Southern

District of Texas, and elsewhere,

RONNELL BOWMAN, and.
RONNIE JACKSON

knowingly and willfully conspired with each other and others, known and unknown
to the Grand Jury, to commit offenses against the United States, namely:
(a) to knowingly sell and otherwise dispose of firearms to prohibited

persons, in violation of Title 18, United States Code, Sections
922(d)(1) and 2(a);

(b) to knowingly transfer firearms, knowing that such firearm would
be used to commit a felony and drug trafficking crime, in violation
of Title 18, United States Code, Sections 924(h) and 2(a);

(c) to knowingly possess and transfer machineguns, in violation of
Title 18, United States Code, Sections 922(0) and 2(a); and

(d) to knowingly possess firearms by a prohibited person, in violation
of Title 18, United States Code, Sections 922(g) and 2(a).

2. To further the conspiracy, the conspirators committed acts in the
Eastern District of Wisconsin, including but not limited to:

(a) On or about December 18, 2020, Javonte Cotton sent a message
to Ronnell Bowman asking to “swap” his Glock firearm and
stating that, “we just found six more switches,” meaning
machineguns.

All in violation of Title 18, United States Code, Sections 371 and 2(a).

8

Case 2:23-cr-00077-JPS Filed 03/11/25 Page8of1i2 Document 780
COUNT SIX

THE GRAND JURY FURTHER CHARGES THAT:

Beginning by at least October 8, 2024, and continuing through on or about
March 7, 2025, in the State and Kastern District of Wisconsin and elsewhere,

RONNELL BOWMAN

did knowingly attempt to intimidate, threaten, and corruptly persuade Witness 1, a
witness known to the Grand Jury, with the intent to influence, delay, and prevent
the testimony of that witness in an official proceeding, namely, the jury trial in
United States v. Ronnell Bowman, et al, Case No. 23-CR-77.

In violation of Title 18, United States Code, Sections 1512(b)(1) and 2(a).

9
Case 2:23-cr-00077-JPS Filed 03/11/25 Page9of12 Document 780
COUNT SEVEN

THE GRAND JURY FURTHER CHARGES THAT:
Beginning on or about October 18, 2024, and continuing through on or about
December 4, 2024, in the State and Eastern District of Wisconsin,
RONNELL BOWMAN
did knowingly attempt to intimidate, threaten, and corruptly persuade Witness 2, a
witness known to the Grand Jury, with the intent to hinder, delay, and prevent that
witness’s communication to a law enforcement officer of information relating to the

possible commission of a federal offense.

In violation of Title 18, United States Code, Sections 1512(b)(8) and 2(a).

10

Case 2:23-cr-00077-JPS Filed 03/11/25 Page10of12 Document 780
COUNT EIGHT

THE GRAND JURY FURTHER CHARGES THAT:

Beginning by at least October 8, 2024, and continuing through on or about
March 7, 2025, in the State and Eastern District of Wisconsin and elsewhere,

RONNELL BOWMAN

knowingly and intentionally conspired with others, known and unknown to the Grand
Jury, to attempt to corruptly obstruct, influence, and impede an official proceeding,
namely, the jury trial in United States v. Ronnell Bowman, et al, Case No. 23-CR-
77.

In violation of Title 18, United States Code, Sections 1512(c)(2), 1512(k), and

2a).

Case 2:23-cr-00077-JPS Filed 03/11/25 Page1ilof12 Document 780
FORFEITURE NOTICE

Upon conviction of the mail fraud conspiracy, as set forth in Count One of this
Second Superseding Indictment, in violation of Title 18, United States Code, Section
1349, the defendants shall forfeit to the United States of America, pursuant to Title
18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section
2461(c), any property, real or personal, which constitutes or is derived from proceeds
traceable to the offense, including, but not limited to a sum of money equal to the

proceeds derived from the offense.

RICHARD G. FROHLIS@S
Acting United States ey

12
Case 2:23-cr-00077-JPS Filed 03/11/25 Page12of12 Document 780


File and source

File

780-superseding-indictment-bowman.pdf

Size

377,158 bytes

SHA-256

45b7839e693d21bbd326b63c4a199296c4592fa4b00048e78e089821c3371b5f

Our copy

780-superseding-indictment-bowman.pdf

Original

PACER (login required)